Motion to Withdraw as Counsel for Named Plaintiff — In re January 2021 Short Squeeze Trading Litigation (Dkt. 575, S.D. Fla.)

Summary

A Motion to Withdraw as Counsel for Named Plaintiff (Document 575) in In re: January 2021 Short Squeeze Trading Litigation, Case 1:21-md-02989-CMA, U.S. District Court for the Southern District of Florida, entered on the FLSD docket June 15, 2023 and relating to Austin Schaff v. Robinhood Markets, Inc., et al., Case No: 1:21-cv-21264-CMA. Pursuant to Local Rule 7.1 and 11.1(d)(3)(A), the Law Firm of Justice Litigation Associates PLLC (formerly Justice for Justice LLC) and Chad A. Justice move to withdraw as counsel for Named Plaintiff Austin Schaff, citing Rule 4-1.16(b) of the Rules Regulating the Florida Bar and the comment that a lawyer's statement that professional considerations require termination of the representation ordinarily should be accepted as sufficient. The three-page motion carries a certificate of service dated June 15, 2023 signed by Chad A. Justice.

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Date: 2023-06-15

Cite this document

“Motion to Withdraw as Counsel for Named Plaintiff (Dkt. 575).” Original at archive.org, dated 2023-06-15. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2023-06-15-austin-schaff-v-robinhood-markets-inc-et-al-case-no/, SHA-256 f9453f976ff040125ca5521ad95f08f0b0bc76edfc7eb0906b7f0ae644e3d334.

Full text

Case 1:21-md-02989-CMA Document 575 Entered on FLSD Docket 06/15/2023 Page 1 of 3

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

Case No.: 21-2989-MDL-ALTONAGA/Torres

In re:

JANUARY 2021 SHORT SQUEEZE
TRADING LITIGATION
/

This Document Relates to:

Austin Schaff v. Robinhood Markets, Inc., et al.
Case No: 1:21-cv-21264-CMA
/

MOTION TO WITHDRAW AS COUNSEL FOR NAMED PLAINTIFF

Pursuant to Local Rule 7.1 and 11.1 (d)(3)(A), the Law Firm of Justice Litigation

Associates PLLC (formerly Justice for Justice LLC), Chad A. Justice (collectively “Justice

Litigation”), hereby file this motion to withdraw as counsel for Named Plaintiff, Austin Schaff

(“Mr. Schaff”), in this action. The undersigned was retained by Mr. Schaff to represent him in the

above-styled case. However, as explained below, Justice Litigation now respectfully moves to

withdraw. In support thereof, Justice Litigation states as follows:

SUPPORTING FACTS

1. Rule 4-1.16(b), Rules Regulating the Florida Bar, states that a lawyer may withdraw

from representing a client if withdrawal can be accomplished without material adverse effect on

the interests of the client, or if the client insists on pursuing an objective that the lawyer considers

repugnant or imprudent, or if the representation will result in an unreasonable financial burden on

the lawyer or has been rendered unreasonably difficult by the client, or if other good cause for

withdrawal exists.

2. The comments to Rule 4-1.16 state that “The court may request an explanation for

the withdrawal, while the lawyer may be bound to keep confidential the facts that would constitute

such an explanation. The lawyer's statement that professional considerations require termination
Case 1:21-md-02989-CMA Document 575 Entered on FLSD Docket 06/15/2023 Page 2 of 3

of the representation ordinarily should be accepted as sufficient.”

3. Professional considerations require termination of the representation in this case.

Plaintiff does not object to the withdrawal of the undersigned counsel.

4. Good cause for withdrawal exists, as the Court dismissed the instant Class Action

through the Court’s Order, entered January 26, 2022. A Notice of Appeal was subsequently filed.

5. Moreover, withdrawal can be accomplished without material adverse effect on the

interests of the aforementioned Named Plaintiff, Mr. Schaff.

6. Because the Rules Regulating the Florida Bar anticipate that the undersigned

counsel may withdraw under the circumstances presented by the facts in this case, and because the

aforementioned Named Plaintiff, Mr. Schaff, will not be prejudiced by the withdrawal of the

undersigned counsel, the undersigned counsel respectfully requests that this Court permit Justice

Litigation to withdraw from representing the aforementioned Named Plaintiff, Mr. Schaff, in this

case.

7. Austin Schaff’s most recent contact information is 225 2nd St NW, Apt. 1203,

Canton, Ohio 44702.

WHEREFORE, for the reasons set forth herein, the undersigned counsel respectfully

requests that this Court permit them to withdraw from this case.

Dated this 15th day of June, 2023

Respectfully submitted,

/ s / Chad A. Justice
Chad A. Justice, Esquire
Florida Bar No. 121559
chad@getjusticeforjustice.com
Justice Litigation Associates
1205 North Franklin Street, Suite 326
Tampa, FL 33602
Telephone: (813) 566-0550
Facsimile: (813) 566-0770
ATTORNEYS FOR NAMED PLAINTIFF
Case 1:21-md-02989-CMA Document 575 Entered on FLSD Docket 06/15/2023 Page 3 of 3

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 15th day of June, 2023 I electronically filed the

foregoing with the Clerk of the Court by using the CM/ECF system, which will send a notice of

electronic filing to all counsel of record.

/ s / Chad A. Justice
Chad A. Justice

File and source

File: gov.uscourts.flsd.590042.575.0.pdf
Size: 183,677 bytes
SHA-256: f9453f976ff040125ca5521ad95f08f0b0bc76edfc7eb0906b7f0ae644e3d334
Our copy: gov.uscourts.flsd.590042.575.0.pdf
Original: archive.org